Search

Labeling Small Limited Quantity Shipments

Posted on 6/18/2013 by James Griffin

Over the next few years, the Department of Transportation is phasing out the old ORM-D classification for consumer commodities and replacing it with an expanded universe of limited quantity authorizations. In most cases, the only difference for the end-user will be replacing the rectangular ORM-D, CONSUMER COMMODITY marking with the new diamond Limited Quantity marking.
 
Many consumer commodity hazmats are transported in small packages, with dimensions only 4 or 6 inches wide. Because the DOT’s new limited quantity marking is larger than the older ORM-D, CONSUMER COMMODITY marking, shippers may have difficulty fitting all necessary marks and labels on smaller consumer commodity packages.
 
Whether the marks/labels are pre-printed or affixed at the time of shipping, it can be expensive to reorganize labels or affix them to the same side of a package to make them fit.
 
In response to questions from industry on this subject, PHSMA released a letter of interpretation on October 1, 2012, that authorizes the use of smaller limited quantity labels in some cases.
 
Shipping Boxes with Limited Quantity Label
 
Hazardous Materials Administration Authorizes Reduced Marking
 
According to the Hazardous Materials Regulations, each limited quantity marking must be durable, legible, of a size relative to the package that is readily visible, and at least 100 mm (4 inches) on each side, unless the package size requires a reduced-size marking. [49 CFR 172.315; emphasis added]
 
This phrase has traditionally been interpreted by shippers to mean that reduced-size markings are authorized only when the full-sized marking will not fit on the package. In the letter of interpretation from October 1, 2012 (12-0177), however, PHSMA authorized reduced-size markings “…to the extent necessary to accommodate pre-printing of [the] additional information needed with the limited quantity marking.”
 
This means that you can use a reduced-size (down to 50 mm) limited quantity marking on a package, even when the full-sized (100 mm) marking will fit. This is similar to provisions that already exist in IATA 7.1.5.3. By using a reduced-size label, you can free up room for other markings to ensure you communicate all the critical information on your package in a way that’s easy for shipping personnel, carriers, and first responders to recognize and use.
 
Learn the latest rules and exclusions available for shipping limited quantities of hazardous materials by ground, air, and ocean! The Shipping Limited Quantities and Consumer Commodities online course covers the 49 CFR, IATA, and IMDG rules your personnel must know to prepare limited quantity shipments for transport by any mode. 
 

Tags: DOT, hazmat shipping, limited quantities, marks and labels

Find a Post

Recent Posts

Compliance Topics

Compliance Archives

Lion - Quotes

I think LION does an excellent job of any training they do. Materials provided are very useful to my day-to-day work activities.

Pamela Embody

EHS Specialist

Best course instructor I've ever had. Funny, relatable, engaging; made it interesting and challenged us as the professionals we are.

Amanda Schwartz

Environmental Coordinator

Given the choice, I would do all coursework this way. In-person courses go very fast without the opportunity to pause or repeat anything.

Ellen Pelton

Chemical Laboratory Manager

Lion's course was superior to others I have taken in the past. Very clear in the presentation and the examples helped to explain the content presented.

George Bersik

Hazardous Waste Professional

I really enjoyed this training. Even after years on both sides of the comprehension coin, I find myself still learning! The quality of the delivery exceeded much of the training I have received in the past.

Neil Ozonur

Safety Officer

Lion provided an excellent introduction to environmental regulations, making the transition to a new career as an EHS specialist less daunting of a task. Drinking from a fire hose when the flow of water is lessened, is much more enjoyable!

Stephanie Weathers

SHE Specialist

The instructor had knowledge of regulations and understanding of real-world situations. The presentation style was engaging and fostered a positive atmosphere for information sharing.

Linda Arlen

Safety & Environmental Compliance Officer

I can take what I learned in this workshop and apply it to everyday work and relate it to my activities.

Shane Hersh

Materials Handler

I was able to present my scenario to the instructor and worked thru the regulations together. In the past, I attended another training firm's classes. Now, I have no intention of leaving Lion!

Diana Joyner

Senior Environmental Engineer

I have over 26 years of environmental compliance experience, and it has been some time since I have attended an environmental regulations workshop. I attended this course as preparation for EHS Audits for my six plants, and it was exactly what I was looking for.

Frank Sizemore

Director of Regulatory Affairs

Download Our Latest Whitepaper

Just starting out with shipping lithium batteries? The four fundamental concepts in this guide are the place to start.

Download
Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.